Paul L. Caron

Wednesday, November 4, 2020

The Tax Guide To Offshore Lending

David S. Miller (Proskauer, New York), The Tax Guide to Offshore Lending (116 pages):

This paper explains the various structures that permit offshore funds with U.S. managers to originate loans without the fund or its investors being subject any meaningful amount of U.S. tax. This paper also suggests a legislative change that would render these structures moot.

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